Policy Writers Workshop February 27, 2018 (Participation is - - PDF document

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Policy Writers Workshop

February 27, 2018

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What is the Policy Program?

• Official resource for all university policy making
• Within the Integrity and Compliance Office (ICO)
• Implemented in 2012 per BOV “policy on policies” (Creating and

Maintaining Policies and Procedures)

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– Shared governance process – Policy approval authority

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What does the Policy Program do?

• Oversees development, review, approval and retirement

processes for university policies and procedures

• Communicates approved policies, etc. to university members
• Administers and maintains Policy Library

– Policy Points quarterly publication

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– Adherence to “policy on policies”

What does the Policy Program do?

• Maintains policy archives
• Sends timely review notices
• Educates/guides university community
• Performs gap assessments
• Scans environment for trends/areas of importance

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What is a policy?

• A policy articulates requirements and expectations for behavior,

actions and activities of the university community. A policy may require or prohibit an action, support compliance with applicable laws and regulations and/or mitigate risk.

So . . .

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What are procedures?

• Procedures are mandatory actions and processes necessary to

comply with a policy.

• Policies may or may not include procedures.

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Why do we need policies?

• Make expectations clear
• Mitigate risk
• Support compliance

– What – Why – Who – How (procedures)

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What is not a policy?

• Guidelines are not policies!
• Guidelines are suggestions or recommendations for a preferred

course of action or behavior; they are not requirements or mandates.

• Guidelines are not enforced like policies, but may be relevant to

implementing a policy (e.g., Related Documents, FAQ, etc.).

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Types of policies at VCU

• Board of Visitors (BOV)

– University governance and/or requires the BOV to take an action item (such as a vote to approve something)

• Administrative

– Universitywide operational expectations and/or compliance with applicable laws, regulations, policies and procedures

• Local

– Meets the unique needs of one unit, division, department or school

• BOV approves
• President’s Cabinet approves
• Not governed by Policy Program (but always happy to help!)

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• Cannot conflict with an Administrative or BOV policy

Interim policies

• Applies to BOV and administrative policies

– Provisional policy that fulfills an emergent need and requires implementation pending the full approval process – President’s Cabinet approves – Limited in term to one year or less

• Accreditation, legal, regulatory or remedial action

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Submission of policy to ICO for review

– Consults with subject matter experts – Submits policy and summary to policy@vcu.edu – Uses current Policy Template – Uses Executive Summary of Proposed Policy template – Gains approval to develop from cabinet member (administrative policy) or president or designee (BOV policy)

• Policy owner . . .

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Submission of policy to ICO for review

– Follows Policy Review Checklist

• Clarity

– Facilitates governance process

• Format (template use, etc.)
• ICO . . .
• Consistency
• Recommendations

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Policy Template

• Provides guidance
• Required
• Contributes to consistency

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Policy Title

• Expresses the purpose and describes the policy
• Followed by “- Interim” for interim policies
• Should not include “Policy”
• Preceded by “[DRAFT]” for draft policies
• Should not include “Virginia Commonwealth University” or

“VCU”

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Policy Type

• BOV
• Interim
• Local
• Administrative

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Responsible Office

• Unit primarily responsible for developing and implementing

the policy

– Trains appropriate audiences – Enforces and monitors compliance – Ensures accuracy of subject matter – Timely review

• Also includes name of cabinet-level office

– Example: Office of Sponsored Programs, Office of Research and Innovation – Interprets policy

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Initial Policy Approved

• The date first version was approved – its “birthday”

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Current Revision Approved

• New policy

– “None – New Policy”

• Revised policy

– Date current version was approved – Minor “out of cycle” revisions do not change the current approval date

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Policy Statement and Purpose

• States VCU’s stance on the topic and purpose of the policy
• States key requirement(s)

 Consequences for noncompliance

– Does not include procedures on how to comply; these go in the Policy Specifics and Procedures section

• Includes separate exceptions section (if applicable)
• States who must follow the policy

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– Standard noncompliance/nonretaliation statement

Example of Policy Statement and Purpose

• Virginia Commonwealth University is committed to maintaining a safe and

supportive environment for all individuals in the university community, particularly minors who participate in VCU sponsored or hosted programs . . . . [VCU’s Stance]

• The purpose of this policy is to bring awareness to the presence of minors on

campus, and to prescribe minimum requirements for the screening, supervision and training of individuals working with minors – to ensure their protection, to fulfill our obligations as mandated by law, and to provide the best possible experience for any minors participating in activities sponsored or hosted by the

• university. In addition, compliance with this policy serves to minimize those risks

associated with activities involving minors for everyone . . . . [Purpose of Policy]

Source: Safety and Protection of Minors

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Example of Policy Statement and Purpose (cont’d)

• This policy applies to all programs and activities that involve non-enrolled minors

and are sponsored by the university or conducted by other organizations on VCU’s campus, including camps, clinics, workshops, conferences, research lab mentorships, and other educational activities . . . . [Who Policy Applies To]

• Minors participating in VCU sponsored or VCU hosted programs and activities

must be conducted in a manner that is appropriate and intended to keep everyone healthy and safe . . . . [Key Requirement(s)]

Source: Safety and Protection of Minors

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Example of Policy Statement and Purpose (cont’d)

Noncompliance with this policy may result in disciplinary action up to and including

• termination. VCU supports an environment free from retaliation. Retaliation

against any employee who brings forth a good faith concern, asks a clarifying question, or participates in an investigation is prohibited. [Consequence for Noncompliance]

Source: Policy Template

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Table of Contents

• Outlines the sections of the document

Source: Policy Template

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Who Should Know This Policy

• The groups that need to be familiar with the policy

– Employees (includes faculty and staff) – Students – Others who may be subject to the policy (vendors)

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Examples of Who Should Know This Policy

• University Business-Related Travel policy

– University employees, non-employees and students seeking reimbursement from any VCU funding source are responsible for knowing this policy and familiarizing themselves with its contents and provisions.

• Classified Employment, Promotion and Transfer policy

– Classified employees, and anyone who hires classified employees, are responsible for knowing this policy and familiarizing themselves with its contents and provisions.

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Definitions

• Limited to new, uncommon or specialized terms that have

unique or particular meaning to the policy or are industry- specific

• Alphabetical order – please!
• Not capitalized in body of policy unless they are proper nouns
• Aid in the reader’s understanding of the policy or procedure
• Do not contain requirements

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Examples of Definitions

• Honorarium

– An honorarium is a token payment to a non-employee or non-student granted in recognition of a special service which custom or propriety forbids any fixed business price to be set. The services involved vary but are generally associated with oral presentations made at university- sponsored functions.

Source: Honorarium

• Disability

– For an individual, a documented physical or mental impairment that substantially limits one or more major life activity, a record of such an impairment, or being regarded as having such an impairment.

Source: Accessibility and Reasonable Accommodation for Individuals with Disabilities

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Contacts

• Name of the unit(s) that is responsible for interpreting and

revising the policy and answering questions about the policy. Also include the title/position of the individual whom to contact and general email account (if available and monitored).

• Do not use personal names, phone numbers or email

addresses as contacts

• Use current official name of unit and position contact

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Example of Contacts

• The Office of Procurement Services officially interprets this
• policy. Procurement services is responsible for obtaining

approval for any revisions as required by the policy Creating and Maintaining Policies and Procedures through the appropriate governance structures. Please direct policy questions to procurement services, travel and corporate card manager.

Source: University Business-Related Travel

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Policy Specifics and Procedures

• Mandatory actions/operational processes/steps required to

comply with the policy

– List in order they should occur – Consistent with Policy Statement and Purpose and other policies – Use numbering and bullets – Use subheadings to define steps and processes

• Who performs the procedure
• What steps are required
• How the steps are to be performed

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Policy Specifics and Procedures

• Draft procedures with the “every reader” in mind
• Involve key stakeholders and subject matter experts

– Benefits the reader and policy owner – Avoids errors – Creates sense of ownership

• Must be able to monitor and enforce

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Policy Specifics and Procedures

• Include procedures that apply to more than one unit/area of

the university community

– Omit strictly “internal” or “local” processes and procedures

• Example: Include requirements and procedures for university travelers

to get reimbursed, but exclude Procurement Services’ internal procedures to process the reimbursement submission

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Policy Specifics and Procedures

• Use direct language conveying mandatory or prohibited action

(e.g., must, required, will and prohibited) rather than language that may be viewed as optional (e.g., should, shall, may or should not)

• Do not include guidelines/recommendations

– But refer to them and list as Related Documents or FAQ

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Example of Policy Specifics and Procedures

• 1. Human Resources Role: Human Resources will post and advertise vacancies, recruit, screen,

assist with selection, consult with managers on salary determinations and authorize a salary offer to be made by the hiring department according to applicable pay practices as established by state policy and the VCU Classified Salary Administration Plan as listed in the Related Documents section

• f this policy . . . .
• 2. Posting of Vacancies: Subject to the exceptions listed below, Human Resources must post, for a

minimum of five working days, all classified positions that become vacant and are to be filled . . . .

• 3. Advertisement: Human Resources is responsible for coordinating placement of all

advertisements for vacant classified and hourly positions and will ensure that advertisements conform to university formatting, language and EEO guidelines . . . .

• 4. Interviews: Interviews are a required step in the selection process. No person is to be hired

without having been interviewed for the posted position . . . .

Source: Classified Employment, Promotion and Transfer

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Forms

• List the forms that are referenced in, or related to, the policy

– Internal forms

• Use current hyperlink for VCU materials

– Federal and state forms

• List URL (but no hyperlink) to external materials
• List in this order: (1) referenced, (2) VCU forms in alphabetical
• rder, and (3) the rest in alphabetical order
• Use current official form tiles

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Example of Forms

Source: Organization Websites, Management and Hosting

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Related Documents

• List documents and resources critical to policy development

and compliance

– Other university policies and procedures – Federal and state regulations, laws and policies – Local policies, procedures, guidelines, standards, etc.

• List in this order: (1) referenced, (2) VCU policies in

alphabetical order, and (3) the rest in alphabetical order

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Related Documents

• Use current hyperlink to VCU materials
• List URL (but no hyperlink) to external materials
• Use current official document titles

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Example of Related Documents

Source: Timely Warning/Crime Alert

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Revision History

• Indicates when changes were made to the policy
• Includes former names of the policy (if applicable)
• Includes approval dates of prior versions

– Minor “out-of-cycle” revision dates and reason for revision are included

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Example of Revision History

Source: Information Security

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FAQ (not “FAQs”)

• Anticipated or commonly asked questions and answers

regarding this policy and procedures

• Offers further interpretation of policy and procedures
• Additional relevant information
• If no FAQ: “There are no FAQ associated with this policy and

procedures.”

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Example of FAQ

Source: Computer and Network Resources

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Executive Summary Template

• Required for new policies

and substantive revisions

• Must accompany draft throughout

review and approval process

• All fields must be completed

– Salient points

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Policy writing tips

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– Consult with subject matter experts

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Policy Writing Tips

– Consult with stakeholders – Research

• Other universities’ policies
• Contact us!
• Planning

– Permission to develop

Policy Writing Tips

– Use plain language – You are writing for the general university audience – the “every reader,” not subject matter experts

• easy to READ
• easy to UNDERSTAND
• easy to USE

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• Drafting

Policy Writing Tips

• Plain language

– Short sentences – Common, everyday words (avoid jargon and slang) – Active voice – Logical organization (headings and sub-headings)

• Active: Subject performs the act stated by the verb

– An employee must prepare the report.

• Passive: Subject is acted upon by the verb

– The report must be prepared by an employee.

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Policy Writing Tips

• Example of plain language

– Hypothetical “Before”: VCU is taking action to help ensure that all employees are able to perform their day-to-day activities and duties in a setting that does not encourage, condone or otherwise tolerate any form of mistreatment or misconduct. – Hypothetical “After”: VCU is committed to maintaining a civil working environment.

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Policy Writing Tips

• Use consistent terminology

– Abbreviations and acronyms

• Use throughout after initial use
• Example: “Integrity and Compliance Office” = “ICO” for

remainder of policy – Terms

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Policy Writing Tips

• Use gender-neutral pronouns/language

– They, them, their, etc.

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• Use generic product names
• Use position titles, not personal names

– Microsoft Word  word processor

Policy Writing Tips

• Test reading ease

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Policy Writing Tips

• VCU editorial style guidelines

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• VCU’s nomenclature, capitalization, punctuation, etc. standards

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VCU editorial style guide

• Communicator’s responsibility to uphold the standards!!!
• University Relations developed

– Adopts AP style – VCU enhancements – Capitalize a formal title immediately preceding a name, but lowercase title if it follows the name or stands by itself

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VCU editorial style guide

• Highlights

– Do not use any punctuation at the end of bulleted items that are not sentences – Do not capitalize “university” when it stands alone or refers to VCU – In the absence of rule, use lowercase rather than capital letters

• Defined terms in policies should be lowercase in body of policy

– Spell out numbers one through nine; use numerals for 10 or more

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VCU editorial style guide

• Highlights

– Use numerals for percentages; spell out “percent” and “percentage” – Do not use serial comma (the comma following the second-to-last item in a series) unless its absence compromises clarity – Do not use “(VCU)” callout after “Virginia Commonwealth University”;

• kay to use “VCU” in subsequent references

AP Stylebook online

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VCU editorial style

Carla Davis Editor cjdavis2@vcu.edu (804) 827-5707 Camille Coy Senior copy editor cscoy@vcu.edu (804) 828-1864

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Policy review and governance

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University Council (UC) review

• UC meets monthly: September - May
• Two phases of UC review
• 1. UC Committee on Academic Affairs and University Policies

(UCAAUP) review

• 2. Full UC review
• Melody Harris is contact to get on UCAAUP agenda
• Jamie Stillman is contact to get on full UC agenda
• Policy owner is responsible for getting on agendas

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University Council (UC) review

• UCAAUP review

– Policy owner presents policy with executive summary – UCAAUP recommends that policy proceed to full UC for review

• Policy becomes a consent item on full UC agenda

– Meets two weeks prior to full UC meeting

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University Council (UC) review

– Policy owner is present for any questions, etc.

• Full UC review

– UC recommends that policy proceed to cabinet for review and approval – Representative from UCAAUP briefs UC on the policy

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President’s Cabinet review and approval

• Cabinet meets every two weeks (generally)
• Respective cabinet member presents policy and executive

summary

• Cabinet approves administrative policies; reviews BOV policies

– Kevin Allison is contact to get on cabinet’s agenda

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Board of Visitors review and approval

• BOV meets quarterly
• BOV approves policy

– Michele Schumacher is contact to get on BOV agenda

• Respective cabinet member presents policy and executive

summary to BOV Audit, Integrity and Compliance Committee

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– Send draft to Paula Gentius in president’s office for cursory review

Triennial (“timely”) review

• At least every three years
• Policy review schedule is located on policy site

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• ICO sends reminders approx. six months prior

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Triennial (“timely”) review

–

• Options

– No revision = no changes – Minor revision = does not alter the scope or application; changing process to align with current business practices – Substantive revision = alters the scope or application; adds or removes requirements or responsibilities for a unit or individual – Retirement – Consolidation with other policies

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policy@vcu.edu atrapchick@vcu.edu 828-2336 828-3982

Questions?

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